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Home My WebLink About00-05327 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 20c0- Civil Action - 53;).t ( X) Law ( ) Equity :il Suzanne Daggs 205 Conodoguinet Ave, Apt. 7 Camp Hill PA 17011 Forrest Leek 47505 Cochran Hill Road Clarington OH 43915 versus Landsiar Ranger, Inc. c/o CT Corp System 208 S. LaSalle Street Chicago IL 60604 Plaintiff(s) & Defendant(s) & Address Address PRAECIPE FOR WRIT OF SUMMONS f' TO THE PROTHONOTARY OF SAID COURT: Please issue Writ of Summons in the above-captioned action. Writ of Summons shall be issued and forwarded to ( X ) Attorney ~_~a Signature of Attorney Supreme Court ID No. 30965 ( ) Sheriff Richard E. Freeburn, Esquire 4775 Linglestown Road, Ste. 200 Harrisburg, PA 17112 (717) 671-1955 Date: '1- ~ '7 - D 0 WRIT OF SUMMONS " TO THE ABOVE-NAMED DEFENDANT(S): FORREST LEEK and LANDSTAR RANGER, INC. YOU ARE NOTIFIED THAT THE ABOVE-NAMED PLAlNTIFF(S) HASIHA VE COMMENCED AN ACTION AGAINST YOU. Is '~iiJJ;J .f-, ~ .(~ 'Prothonotary ItP\<l$ Date: j.' 3 \ -Ob By: ~~ 41;. ~~ ik Depufy (J ~ ~ " I I I I , I I " " , "j " Ii !;I .,: " I): 11; g: !f i1 " !} II! i!j li1 iJ ii.l !l~i ",I, 1(1 ii'l li:l, !I\\ (;1 111 ii 1"1 ;::1 i>1 ;,,1 ;:':'1 i:,;! ~ ik- ~ ~ ~ ~ - - ..>lINt () ! .... p -C ~ I~ d t -l-. !> -..::. ~ :b ~ "'~, . ~ C' C;' :-~~ ~~! >- ~(" ~;~~ ::-! f :> "~~ """~I~""" )> S? '-.~) C,.,J .-=:. '~~) f:-:; 17"'R',~ '", SUZANNE DAGGS, Plaintiff v. IN THE COURr OF COMMON PLEAS CUMBERLAND COUNTI, PENNSYLVANIA NO. 2000-5327 CIVIL ACTION - LAW FORREST LEEK; and LANDSTAR RANGER, INC. PROOF OF SERVICE I hereby certify that I served Writs of Summons in the above- captioned matter by certified mail, retum receipt requested, on August 3, 2000, by depositing a copy of the same in the United States Mail, Certified Mail-Return Receipt Requested,' Harrisburg, Pennsylvania, with special prepaid postage. The postal return receipts evidencing said acceptance of service are attached hereto. Respectfully submitted, FREEBURN & ASSOCIATES B}c ~<~~ Richatd E. eebum, Esquire LD. No. 30965 4775 Linglestown Road, Suite 200 Harrisburg, PA 17112 (717) 671-1955 Dated: 8/14/00 Attomey for Plaintiff '"~ ~ ,~ - '-1<"-- c" ",",~ U1 .... .... ..D I I I I I I- ..D "" U1 l'- Postage Certified Fee ::T .... CJ CJ R",turn Rec~ipf Fee (Endorsement Required) Restricted Delivery Fee (Endorsement RequJred) CJ CJ ::T fT1 Total Postage & F~es .... .... CJ l'- . Complete items 1, 2, a~d'3,' Al~o"c6~p'lete . item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the carel to you. . Attach this card to the back of the mall piece, or on the front 'if space permits. 1, Article Addressed to: D, Is delivery address' dittereii m'item 1 If YES, enter delivery address below: F~rrest Ioeek 47505 Coc~ran Hill Road Clarington OH 43915 3, SelVice Type XXCertlfled Mail 0 Express Mail o 'Registered 0 Return Receipt for Merchandise o Insured Mail 0 C,Q,D, 4. Restricted Delivery? (Extra Fee) XI Yes -.".- >,r,'",,'.. 1''',- ,. --,--, ., ,On 102595-99-M-1'189 .' . I~'''' . ... "" .... ...lI Postage $ 3 Certified Fee L(D , Return R,ei:::eipt Fee /) e::- (Endorsement,Recjulred) I ()t:> Restricted Dellv'eryFee (Endorsement Required) "" C :;r IT1 Total Postage & Fees $ }. 9/'D' ...lI .., U1 I"- :;r .... C. C tr tr "" I"- FI&cipfent,'s Name (Please Print Clearly) (to be completed by mailer) Landstar, Ranger, Inc. '~i1tii"Pt:~:;'o;~;~:fi~---St:._mmmmm_mmm..._m 7;!li-s[tiire:zij5+4---n~_n--------------------------------------------------------------.'u ~nlcago IL 60604 - _ -= "i..J:Cu-i' COMPLETe TdlS Sc:C (;Oi,1 I COMPLETE Ti-JIS SEe no/v ON DELIVERY . Ctlmph9te ite'ms 1, 2, and 3. Also complete Item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you, ~ l". C. Signature . AlIach this card tc tho back cf the maSeIJ';1l!l BcPORA TIOK S,.... or on the front If space permits. ' :" .I- . .,:."'; ,. , 0:1 SdXtWii&!fWir item 1? 1. Art'CleAddressedtO:ap.'t 'AG~~1'!l!:fl\~~tti'6'a4: Lands~ar Ranger,Inc. c/o CT Corp System 2118 S.LaSalle Street Chicage IL 60604 CJ Agent Addressee Dyes D No 3, ServIce Type )(Xcertified Mail D Registered o Insured Mail o Express Mail o Return Receipt for Merchandfse DC.D.D. 4, Restricted Delivery? (Extra Fee) D'Yes ,'~N~lf;~~r.r"~f'g,) 6J8h: PS Fo"" a811. JUly 1999 [)"",esti. Return_pi 102595-99.M.1789 "c -,",,_ >,~",' ~'<c","~ c',O- ~ I,'" ,'" " ~Ii1llimiIIl;HIl_I!f,~,~. ~~o ,.~ ""'..~ --. -,~..'"'' 0 = 0 c C) - Tl < ",. ~co i= nriD ,:;-, ::T1 2::1.' ,-:: :z:c I (/).-<--' O'i -:>S~l -<:' ~C , '-', " -T ~,-. ~.,~ ~-:! (') C) >c So' ;'--"~,nj '.~~ 2 ~--l :< ':J ...:t::" ()1 :u -< ""," '''''~'~'''1!'1l<f_~l'l!i'g~~ili_.m~~I~~f11(111~~~ SUZANNE DAGGS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-5327 FORREST LEEK; and LANDSTAR RANGER, INC. CIVIL ACTION - LAW NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Ri';&r~, E'quire FREEBURN & HAMILTON 4415 North Front Street Harrisburg PA 17110 (717) 671-1955 I.D. #30965 Date: 10/23/01 Attorney for Plaintiff " :'. ,-1 SUZANNE DAGGS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-5327 FORREST LEEK; and LANDSTAR RANGER, INC. CIVIL ACTION - LAW NOTICE Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene viente (20) dias de plazo al partir de la fecha de la demanda y la notification. Usted debe presentar ua apariencia esrita 0 en persona 0 por abogado y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso 0 notificacion y por cualquier queja 0 alivio que es pedido en la peticion de demanda. Usted puede perder dinero 0 sus propiedades 0 otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA OR LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 \{Z?/I) Richard E. Freeburn, Esquire FREEBURN & HAMILTON 4415 North Front Street Harrisburg PA 17110 (717) 671-1955 LD. #30965 Date: 10/23/01 Attorney for Plaintiff i, ii II :1 iI !i,'" ,," --'-r, ~ .. >" ,,' "t' SUZANNE DAGGS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-5327 FORREST LEEK; and LANDSTAR RANGER, INC. CIVIL ACTION - LAW COMPLAINT AND NOW, comes Plaintiff, Suzanne Daggs, by her attorneys, Freeburn & Hamilton, and files the following Complaint: 1. Plaintiff, Suzanne Daggs, is an adult individual who resides at 205 Conodoguinet Avenue, Apt. 7, Camp Hill, Cumberland County, Pennsylvania. 2. Defendant, Forrest Leek, is an adult individual who resides at 47505 Cochran Hill Road, Clarington, Ohio. 3. Defendant, Landstar Ranger, Inc., is a corporation organized under the laws of the State of Illinois, with offices at 801 North Cass Avenue, Ste. 300, Westmont, Illinois. 4. At all times relevant hereto, Defendant, Forrest Leek, was an employee of Landstar Ranger, Inc., acting within the scope of his employment. 5. The facts and occurrences hereinafter related took place on or about August 26, 1998 at approximately 7:30 a.m. on the eastbound lanes of SR581 in Lower Allen Township, Cumberland County, Pennsylvania. 6. At that time and place, Plaintiff was operating her 1988 Mercury Topaz automobile east on SR581. I " 0 .~ ~ ~ 7. At that time and place, Defendant, Forrest Leek, was operating a 1984 Kenworth T4000 owned by Landstar Ranger, Inc. east on SR581 behind Plaintiffs automobile. 8. At that time and place, Plaintiff stopped her automobile for traffic ahead. 9. At that time and place, Defendant, Forrest Leek, failed to bring the vehicle that he was operating to a stop before the front portion of the vehicle collided with the rear portion of Plaintiffs automobile. 10. The foregoing accident and all of the injuries and damages set forth hereinafter sustained by Plaintiff are the direct and proximate result of the negligent, careless, wanton and reckless manner in which Defendant, Forrest Leek operated his motor vehicle as follows: a. In operating his vehicle at an excessive rate of speed under the circumstances; b. In failing to have his vehicle under proper and adequate control; c. In failing to apply his brakes in time to avoid the collision; d. In failing to observe Plaintiffs vehicle on the highway; e. In failing to operate his vehicle in accordance with the existing traffic conditions and traffic controls; f. In permitting or allowing his vehicle to strike and collide with the rear of the vehicle operated by Plaintiff; 2 ,,"~ ~ '"j'-,''' , Or' , g. In failing to drive at a speed and in the manner that would have allowed Defendant to stop within the assured clear distance ahead; h. In failing to keep a reasonable lookout for other vehicles lawfully on the roadway; and 1. Driving a vehicle upon the highway in a manner endangering persons and property and in a reckless manner with careless disregard to the rights and safety of others and in violation of The Motor Vehicle Code of the Commonwealth of Pennsylvania. 11. Defendant, Forrest Leek's actions constitute negligence per se. 12. By reason of the aforesaid collision, Plaintiff sustained painful and severe injuries to her nerves, bones and soft tissues, which include, but at not limited to head, neck, shoulder and back injuries. 13. By reason of the aforesaid collision and Plaintiffs injuries, Plaintiff has suffered a heightened possibility that she will suffer other or additional injury in the future, and claim is made therefore. 14. The aforesaid injuries sustained by Plaintiff may have aggravated or been aggravated by an existing infirmity, condition or disease, resulting in a prolongation or worsening of the injuries and an enhanced risk of future harm to Plaintiff, and claim is made therefore. 15. By reason of the aforesaid collision and Plaintiffs injuries, Plaintiff was forced to incur liability for the expenses of reasonable and necessary medical tests, medical examinations, medical treatment, medications, hospitalizations and similar expenses in an effort to diagnose her injuries and to restore herself to health and, to the extent permitted by law, claim is made therefore. 3 , ,< '"",1",1'1 - - ~ 16. Plaintiff has not fully recovered from her injuries and it is reasonably likely that she will incur similar expenses in the future, and claim is made therefore. 17. By reason of the aforesaid collision and injuries, Plaintiff has suffered a loss of earnings and earning capacity and is entitled to recover the value of the time, earnings and employment benefits she has lost and which she might reasonably have earned in the pursuit of her ordinary calling and, to the extent permitted by law, claim is made therefore. 18. Plaintiff has not fully recovered from her injuries and it is reasonably likely that she will incur a loss of earnings and earning capacity in the future, and claim is made therefore. 19. By reason of the aforesaid collision and injuries, Plaintiff has incurred incidental costs and expenses, the exact amount of which cannot be ascertained at this time, and claim is made therefore. 20. By reason of the aforesaid collision and injuries, Plaintiff has undergone and in the future will undergo great physical and mental pain and suffering, great inconvenience in carrying out her daily activities, loss of life's pleasures and enjoyment, and claim is made therefore. 21. By reason of the aforesaid collision and injuries, Plaintiff has been subjected to severe humiliation, embarrassment, shame, worry and anger. 4 , , ' 0'" ',' _, ~ ,. ,-,. 22. By reason of the aforesaid collision and injuries, Plaintiff has been subjected to severe mental anguish, emotional distress, nervous shock, fright and horror. 23. By reason of the aforesaid collision and injuries, Plaintiff will continue to endure great mental anguish, emotional distress, shame, worry and anger in the future. 24. By reason of the aforesaid collision and injuries, Plaintiff continues to be plagued by persistent pain and limitation and, therefore, avers that her injuries may be of a permanent nature, causing residual problems for the remainder of her lifetime, and claim is made therefore. 25. As a result of the aforesaid accident, Plaintiff has sustained a disfigurement, and claim is made therefore. COUNT I Suzanne Dal!l!s. Plaintiffv. Forrest Leek. Defendant 26. Plaintiff incorporates herein by reference thereto the averments contained in paragraphs 1-25 above as though set forth herein in their entirety. WHEREFORE, Plaintiff, Suzanne Daggs, demands judgment in her favor and against Defendant, Forrest Leek, in an amount in excess of TWENTY-FIVE THOUSAND & 00/100 DOLLARS ($25,000.00), exclusive of interest and costs, and in excess of the jurisdictional amount requiring compulsory arbitration. 5 ,," . ", . -- ,.. .. ,<, ~', ",. "' --, , ;,~' - rj COUNT II Suzanne Dae:e:s. Plaintiffv. Landstar Rane:er. Inc.. Defendant 27. Plaintiff incorporates herein by reference thereto the averments contained in paragraphs 1-26 above as though set forth herein in their entirety. 28. At all times hereto, Defendant, Forrest Leek, was employed by Defendant, Landstar Ranger, Inc., acting within the course and scope of his employment, furthering the interests, activities, affairs or business of Landstar Ranger, Inc. 29. Defendant, Landstar Ranger, Inc., is liable to Plaintiff for the negligent and wrongful actions of Defendant, Forrest Leek, as set forth above. WHEREFORE, Plaintiff, Suzanne Daggs, demands judgment in her favor and against Defendant, Landstar Ranger, Inc., in an amount in excess of TWENTY-FIVE THOUSAND & 00/100 DOLLARS ($25,000.00), exclusive of interest and costs, and in excess of the jurisdictional amount requiring compulsory arbitration. Respectfully Submitted, By: Richard . Freeburn, Esquire I.D. No. 30965 4415 North Front Street Harrisburg PA 17110 Date: 10/23/01 Counsel for Plaintiff 6 , ' ."" "',-, 1','':'' " , -',' ;j'] VERIFICATION I hereby verify that the statements in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Dated: Itl- /7" () I ~'f~>.'" - " . - ,'I "1 ~~ - Jefferson J.Shipman, Esquire I.D. #: 51785 GOLDBERG, KATZMAN & SHIPMAN, P.C. 320 Market street P.O. Box 1268 Harrisburg, PA 17108-1268 Telephone: (717) 234-4161 Attorneys for Defendants. Plaintiff SUZANNE DAGGS, vs. FORREST LEEK and LANDS TAR RANGER, Defendants TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO 2000-5327 CIVIL ACTION - LAW JURY TRIAL DEMANDED PRAECIPE PLEASE ENTER the appearance of the undersigned on behalf of the Defendants, Forrest Leek and Landstar Ranger, Inc., in the above-captioned matter. ~~;9E; "II ~ 101 ,'," -'. " _, >',"', ",-,,"," - _~'^ ,r~"" '~.-'i'"'.. "~,. . __.' '},. .'"." "'"" 'i_ , ,,"~'",., SHIPMAN, P.C. Je f son J. Shipma 32 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Defendants .-..- ~ > .- . CERTIFICATE OF SERVICE I hereby certify that I served a copy of the foregoing document upon all counsel of record by depositing the same in the United States Mail, first class, postage prepaid, in Harrisburg, Pennsylvania, addressed as follows on ~: Richard E. Freeburn, Esquire 4415 North Front Street Harrisburg, PA 17110 Attorney for Plaintiffs GOLDBERG, KATZMAN & SHIPMAN, P.C. J ferson J. Ship an, Esquire Attorney I.D. 51785 P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4161 Attorneys for Defendants DATE: 71380.1 '"'~~,'-5'"',',_",,,,~,~_,, +" ~"" ,,_,~,,_, ",.. '", ~ " ~ v ", ~,- " '-'", --' "~'" ,~ (') C"J 0 C ~n -;>>. Z "'OED C:J " n1rn "'C: r"~ Z::u -':;2j -;7 t;'- (j) 0=,:;- ':-'~f.> kC:J: -0 ~ , ,1 Is: __, :J; , C) 2::"" ~ C 1\-) ~'.'-;:;;iT >~ ~ ~ ,:..;> ::0 ,-,.,J -< , '" ~ . ,D[' ,. Jefferson J. Shipman, Esquire Attorney I. D. No. 51785 GOLDBERG, KATZMAN & SHIPMAN, F.C. 320 Market Street P.O. Box 1268 Harrisburg, FA 17108-1268 Telephone: (717) 234-4161 Attorneys for Defendants Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SUZANNE DAGGS, vs. NO 2000-5327 FORREST LEEK and LANDSTAR RANGER, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED NOTICE TO PLEAD TO: Plaintiff and her Attorney, Richard E. Freeburn, Esquire 4415 North Front Street Harrisburg, PA 17110 YOU ARE HEREBY notified to plead to the within New Matter of Defendants within twenty (20) days of service hereof. GOLDBERG, KATZMAN & SHIPMAN, P.C. e./l/ J fferson J. Shi man, Esquire Attorney I.D. 51785 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Defendants DATE: 12-1 (] {()I 71612.1 '.'" "'o"""-~:~ . ^",-." ".",.<,",_ ,. ,-, ~"~_,' C_"', ,'" ~..^"" =d~'~'_ , ~.- --. Jefferson J.Shipman, Esquire 1. D. #: 51785 GOLDBERG, KA1ZMAN & SHIPMAN, P.C. 320 Market Street P.O. Box 1268 Harrisburg, FA 17108-1268 Telephone: (717) 234-4161 Attorneys fo~ Defendants. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SUZANNE DAGGS, VS. NO 2000-5327 FORREST LEEK and LANDSTAR RANGER, Defendants CIVIL ACTION - LAW JURY TRIAL DEMANDED ANSWER AND NEW MATTER OF DEFENDANTS, LANDSTAR RANGER. INC.. AND FORREST LEEK AND NOW, comes the Defendants, Landstar Ranger, Inc., and Forrest Leek, by and through their counsel, Goldberg, Katzman & Shipman, P.C., and file the following Answer and New Matter: 1. Admitted upon information and belief. 2. Admitted. 3. Admitted. 4. Denied. The averments contained in Paragraph 4 are conclusions of law to which no response is required. 5. Admitted upon information and belief. 6. Admitted upon information and belief. 7. Admitted. ~ , "/:"'<-~'"_<h"',!,,.,"-"',~.",, '?'''''' ",'''_~.,._ ~,_,~ ,'''''~ >,'~",," """,",'0,<,',,, _ ' "'" ,~^,_ "_,~, . 8. Denied. After reasonable investigation, the answering Defendants are without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 8 and the same are, therefore, denied and strict proof demanded at the time of trial. 9. Admitted in part, denied in part. It is admitted only that there was a collision between the two vehicles. The remaining averments of Paragraph 9 are conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied and strict proof demanded at the time of trial. 10. Denied. The averments contained in Paragraph 10 and subparagraphs (a) through (i) are conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. By way of further response, it is specifically denied that the Defendants were in any way negligent, careless, wanton and reckless. (a) Denied. It is specifically denied that Mr. Leek operated his vehicle at an excessive rate of speed under the circumstances; 2 '-~"'~"",~,~, ",.. ~, ,_,""'~"",. .._'"( . V,''. . ~ ~._< ~ ~, (b) Denied. It is specifically denied that Mr. Leek failed to have his motor vehicle under proper and adequate control; (c) Denied. It is specifically denied that Mr. Leek failed to apply his brakes in time to avoid the collision; (d) Denied. It is specifically denied that Mr. Leek failed to observe Plaintiff's vehicle on the highway; (e) Denied. It is specifically denied that Mr. Leek failed to operate his vehicle in accordance with the existing traffic conditions and traffic controls; (f) Denied. It is specifically denied that Mr. Leek was negligent in allegedly permitting or allowing his vehicle to strike and collide with the rear of the Plaintiff's vehicle; (g) Denied. It is specifically denied that Mr. Leek failed to drive at a speed and in a manner that would have allowed him to stop within the assured clear distance ahead; (h) Denied. It is specifically denied that Mr. Leek failed to keep a reasonable lookout for other vehicles lawfully on the roadway; and (i) Denied. It is specifically denied that Mr. Leek drove a vehicle upon the highway in a manner enpangering 3 ",,", ,'" ',~':' ",,, ,~" I ,~~~,,. ." ,'''~, "',,',,_,"'__'" , ',_ ~ , > ,- ",','- persons and property and in a reckless manner and with careless disregard for the rights and safety of other and in violation of the motor vehicle code of the Commonwealth of Pennsylvania. 11. Denied. The averments contained in Paragraph 11 are conclusions of law and fact to which no response is required. If a response is deemed to be required, it is specifically denied that Mr. Leek's actions constituted negligence per se. 12. Denied. After reasonable investigation, the answering Defendants are without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 12 relating to Plaintiff's alleged injuries and the same are, therefore, denied and strict proof demanded at the time of trial. 13. Denied. After reasonable investigation, the answering Defendants are without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 13 relating to Plaintiff's alleged injuries and the same are, therefore, denied and strict proof demanded at the time of trial. 14. Denied. After reasonable investigation, the answering Defendants are without sufficient knowledge or information to form a belief as to the truth of the averments contained in 4 I', ",1'~,~.' '" ~" >"',"" ,,".,,_ ....."",_ _~t>~-, "h,' "' ~",,~ "~_,,,,_.~, _.~. :~ Paragraph 14 relating to Plaintiff's alleged injuries and the same are, therefore, denied and strict proof demanded at the time of trial. 15. Denied. After reasonable investigation, the answering Defendants are without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 15 relating to Plaintiff's alleged expenses and medical treatment and the same are, therefore, denied and strict proof demanded at the time of trial. 16. Denied. After reasonable investigation, the answering Defendants are without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 16 relating to Plaintiff's alleged injuries and expenses and the same are, therefore, denied and strict proof demanded at the time of trial. 17. Denied. After reasonable investigation, the answering Defendants are without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 17 relating to Plaintiff's alleged loss of earnings and earning capacity and the same are, therefore, denied and strict proof demanded at the time of trial. 18. Denied. After reasonable investigation, the answering Defendants are without sufficient knowledge or information to 5 ;t:1<, ',' ", .- ,~"". _'" .,.,.., ". ~, ~.."'"~_~,"" ". HO.. ,." form a belief as to the truth of the averments contained in Paragraph 18 relating to Plaintiff's alleged injuries and damages and the same are, therefore, denied and strict proof demanded at the time of trial. 19. Denied. After reasonable investigation, the answering Defendants are without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 19 relating to Plaintiff's alleged injuries and expenses and the same are, therefore, denied and strict proof demanded at the time of trial. 20. Denied. After reasonable investigation, the answering Defendants are without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 20 relating to Plaintiff's alleged pain and suffering and loss of life's pleasures and enjoyment and the same are, therefore, denied and strict proof demanded at the time of trial. 21. Denied. After reasonable investigation, the answering Defendants are without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 21 relating to Plaintiff's alleged humiliation, embarrassment, shame, worry and anger and the same are, therefore, denied and strict proof demanded at the time of trial. 6 " . "'"', ,'"0"" ;_,,,,~, ~'c-^'h" or, I ~,,,, ,,,~ . -~ ~ " 22. Denied. After reasonable investigation, the answering Defendants are without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 22 relating to Plaintiff's alleged mental anguish, emotional distress, nervous shock, fright and horror and the same are, therefore, denied and strict proof demanded at the time of trial. 23. Denied. After reasonable investigation, the answering Defendants are without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 23 relating to Plaintiff's alleged mental anguish, emotional distress, shame, worry and anger and the same are, therefore, denied and strict proof demanded at the time of trial. 24. Denied. After reasonable investigation, the answering Defendants are without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 24 relating to Plaintiff's alleged pain and limitations and the same are, therefore, denied and strict proof demanded at the time of trial. 25. Denied. After reasonable investigation, the answering Defendants are without sufficient knowledge or information to form a belief as to the truth of the averments contained in Paragraph 25 relating to Plaintiff's alleged disfigurement and 7 I: -"Y".."<,--,,,,,,,", - , " "1' ." y, ',' ,'- -"'-'- ~<- , ,,~. - .~ the same are, therefore, denied and strict proof demanded at the time of trial. COUNT I SUZANNE DAGGS v. FORREST LEEK 26. Defendant, Forrest Leek, incorporates herein by reference the answers to Paragraphs 1 through 25 above as though fully set forth herein at length. WHEREFORE, the Defendant, Forrest Leek, respectfully requests that judgment be entered in his favor and that Plaintiff's Complaint be dismissed with prejudice. COUNT II SUZANNE DAGGS v. LANDSTAR RANGER. INC. 27. Defendant, Landstar Ranger, incorporates herein by reference the answers to Paragraphs 1 through 26 above as though fully set forth herein at length. 28. Denied. The averments contained in Paragraph 28 are conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. 8 " ~, ". roo_ '<.~'1'""."'c .,~. ,.,,~ < ='8'o~".,," .o",.~ 0; 29. Denied. The averments contained in paragraph 29 are conclusions of law and fact to which no response is required. If a response is deemed to be required, the averments contained therein are specifically denied. WHEREFORE, the Defendant, Landstar Ranger, Inc., respectfully requests that judgment be entered in its favor and that Plaintiff's Complaint be dismissed with prejudice. NEW MATTER By way of additional answer and reply, Defendants, Forrest Leek and Landstar Ranger, Inc., interpose the following New Matter defenses. 30. That the Plaintiff's injuries and damages, if any, were not caused by any act, omission or breaches of duty by the answering Defendants. 31. That any damages the Plaintiff may be entitled to recover in this action are limited to those damages which are recoverable under the provisions of the Pennsylvania Motor Vehicle Financial Responsibility Law, 75 Pa. C.S.A. ~1701, et seq. 32. That if it should be found that there was any negligence on the part of the answering Defendants, which 9 1~ ^ . '-" .'~ "'. ""'1<;'0~"_'?o~,.n',,' I"'''''' ,_0,'" ,,'~,c,.' "-,'r~,,,<r,,,., ~, .""'" , ,'" negligence is expressly denied, any such negligence was not a proximate cause of any injuries or damages to the Plaintiff. 33. That the accident and any resulting injuries were caused in whole or in part by a sudden emergency. 34. That the accident and any resulting injuries may have been caused by an unavoidable accident. 35. That the accident and any resulting injuries may have been caused by an intervening, superseding cause. 36. That the Plaintiff's alleged cause of action may be barred by the statute of limitations. 37. That the accident and any resulting injuries to Plaintiff may have been caused in whole or in part by the negligence of third persons or entities not presently involved in this action. 38. That the Plaintiff's claims may be barred or limited by the pennsylvania Comparative Negligence Act, 42 Pa. C.S.A. ~7l02, et seq., and by the doctrine of comparative negligence. 39. That the Plaintiff may have failed to exercise reasonable care for her own safety under the circumstances then and there existing. 10 ,~ "'-, ',' "",', _":""" "T":~'..I'" ""',"~ ,~__",,,,,,,~'~"_'"" ,,~ WHEREFORE, the Defendants, Forrest Leek and Landstar Ranger, Inc., respectfully request that judgment be entered in their favor and that Plaintiff's Complaint be dismissed with prejudice. GOLDBERG, KATZMAN & SHIPMAN, P.C. 1-~ J fferson J. Sh pman, Esquire 3 0 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Defendants DATE: l2-ll ~ fO l 71612.1 \ \ 11 -'" ',- , "-'C'^" ,- " r: -,<' """,""'"r"-" . ,.' ~, ".~' " -;c~.-, .' ,'__',<- "~'" . ~ ~", "~ Vi VERIFICATION I, FORREST LEEK, hereby acknowledge that I am a Defendant in this action; that I have read the foregoing document and that the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made, subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. ~~ Forrest Leek Date: II-J3-oL - > ~_, ,~ < ""'-"",'" _,~'. -' _"'7-"" ,___ ,_ ,i."I., ,] Ij Ii l 'I :1 'j " '!1 -'" ~. ~O' ~ _ ~"'I"1!lI.{", " ,. v,~ "~- ,," "" r" ',- ,- "nlf "Oflr:I"fi \,!, .~ (" J ru.;:r""" ~'1"" ' ,.~, .',-, ' ~, .,".~, ""';, :{, VERIFICATION I, William C. Burns , hereby acknowledge that Ranger Landstar, Inc., is a Defendant in this action and I am authorized to make this verification on its behalf; that I have read the foregoing document and that the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. RANGER LANDSTAR, INC. J~C!-;t~ Da te: December 11, 2001 I", ."''',' ' ,'~, -P_"",,__' "'.--; ~'_ ,~,~ _ .,'~v ,,_ _ _,__ ,~'. 'r~" ~ CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing has been duly served on the following counsel of record, by depositing the same in the United States Mail, postage prepaid, in Harrisburg, Pennsylvania, on ~: Richard E. Freeburn, Esquire 4415 North Front Street Harrisburg, PA 17110 GOLDBERG, KATZMAN & SHIPMAN, P.C. son J. Shipm #: 51785 P.O. Box 1268 Harrisburg, PA 17108-1268 Attorneys for Defendant " ,- ,~, " -" ''t''--- ,,,""" ,,", -" 1 ," r "''",Y,, "" " ' ",~~ " " " <-,'; -" " ,~ "" - ,." ". ,,',< '- " "~~"c""'< .~~, "'" ,",,-.' 'J "i -,..r';"!,',7''''''''',~'''--''''';_ ~.", '" -C,-'f ,,')i <'"I"""""' C', ,,:;:,~,~]l!liIqllJ!! 1!l', O"~'/"""'~.' ,~ ~ .", ''fiJ SUZANNE DAGGS, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-5327 FORREST LEEK; and LANDSTAR RANGER, INC. CIVIL ACTION - LAW REPLY TO NEW MATTER AND NOW, comes Plaintiff, Suzanne Daggs, by her attorneys, Freeburn & Hamilton, and files the following Reply to New Matter: 30. It is specifically denied that Plaintiffs injuries and damages were not caused by any acts, omissions or breaches of duty by the Answering Defendants. To the contrary, Plaintiffs injuries and damages were caused by the acts, omissions and breaches of duty by Answering Defendants. By way of further reply, Plaintiff incorporates herein by reference thereto each and every allegation contained in her Complaint. 31. This paragraph contains no averments of fact, only conclusions of law, to which no reply is required. To the extent that a court determines that this paragraph contains any averments of fact, the same are specifically denied. 32. This paragraph contains no averments of fact, only conclusions of law, to which no reply is required. To the extent that a court determines that this paragraph contains any averments of fact, the same are specifically denied. ~J 33. This paragraph contains no averments of fact, only conclusions of law, to which no reply is required. To the extent that a court determines that this paragraph contains any averments of fact, the same are specifically denied. By way of further reply, Plaintiff specifically denies that the accident and her injuries were caused by a sudden emergency. 34. This paragraph contains no averments of fact, only conclusions of law, to which no reply is required. To the extent that a court determines that this paragraph contains any averments of fact, the same are specifically denied. By way of further reply, Plaintiff specifically denies that the accident and her injuries were caused by an unavoidable accident. 35. This paragraph contains no averments of fact, only conclusions of law, to which no reply is required. To the extent that a court determines that this paragraph contains any averments of fact, the same are specifically denied. By way of further reply, Plaintiff specifically denies that the accident and her injuries were caused by an intervening, superseding cause. 36. This paragraph contains no averments of fact, only conclusions of law, to which no reply is required. To the extent that a court determines that this paragraph contains any averments of fact, the same are specifically denied. 37. Plaintiff specifically denies that the accident and her injuries were caused by the negligence of third persons or entities not present involved in this action. 2 c" I-I' 38. This paragraph contains no averments of fact, only conclusions of law, to which no reply is required. To the extent that a court determines that this paragraph contains any averments of fact, the same are specifically denied. By way of further reply, Plaintiff specifically denies that the accident and her injuries were caused by any negligence on her part, the existence of any such negligence being expressly denied. 39. Plaintiff specifically denies that she failed to exercise reasonable care for her own safety under the circumstances then and there existing. WHEREFORE, Plaintiff, Suzanne Daggs, respectfully requests that this Honorable Court dismiss Defendants' New Matter, and enter judgment in her favor and against Defendants, Forrest Leek and Landstar Ranger, Inc., in an amount in excess of TWENTY-FIVE THOUSAND & 00/100 DOLLARS ($25,000.00), exclusive of interest and costs, and in excess of the jurisdictional amount requiring compulsory arbitration. Respectfully Submitted, FREEBURN & HAMILTON By: CK4~ Richard E. Freeburn, Esquire LD. No. 30965 4415 North Front Street Harrisburg PA 17110 (717) 671-1955 Date: 1/4/02 Counsel for Plaintiff 3 ',I --II' VERIFICATION I hereby verify that the statements in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Dated: 1;;),- 3 )-0/ A_ ~ AUZ~ r .,~-" I r ";' CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Plaintiffs Reply to New Matter has been duly served on the following this 4th day of January, 2002, by placing the same in the U.S. First Class Mail, postage prepaid, at Harrisburg, Pennsylvania, addressed as follows: Jeffrey J. Shipman GOLDBERG KATZMAN & SHIPMAN, PC PO Box 1268 Harrisburg PA 17108-1268 BY: \J2v/L LP Richard E. Freeburn, Esquire Attorney l.D. #30965 FREEBURN & HAMILTON 4415 North Front Street Harrisburg, PA 17110 (717) 671-1955 Dated: 1/4/02 Attorney for Plaintiff ~-- " -~, -_. ...- - o c -p~ rnrn 2:"1) L.:_C' (.q~:,,: -<,,"";m r..:..-..:c; ~f=; :Jo'C Z ::;:l Cl r'.,) r) "7'1 ,- .~-,~J>>o Z I \.D ~~J~~ ;.. ,'\. ~--~ ("') ~~rn :r,; :::0 -< .''''0 ....i>... N o -.~ _">.~~nl!!f~I!iI9"!l!i:j~~I,"",,,~~~ ~~. ~"" , . , . Jefferson J. Shipman, Esqnire LD. #51785 GOLDBERG, KATZMAN & SHIPMAN, P.c. 320 Market Street P.O. Box 1268 Harrisbnrg, PA 17108-1268 (717) 234-4161 Counsel for Defendants, Forrest Leek and Landstar Ranger, Inc. SUZANNE DAGGS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. NO. 2000-5327 FORREST LEEK and LANDSTAR RANGER, INC, Defendants CIVIL ACTION - LAW CERTIFICATE PREREOUISITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendants hereby certifY that: (1) A Notice OfIntent To Serve A Subpoena, with a copy of the subpoenas attached thereto, was mailed, via Certified Mail, or delivered to each party at least twenty days prior to the date on which the subpoenas were sought to be served; (2) A copy of the Notice OfIntent, including the proposed subpoenas, is attached to this Certificate; (3) No objection to the subpoenas have been received; and (4) The subpoenas to be served are identical to the subpoenas attached to the Notice Of Intent. ,,' , :-_~ 0"""'" _'_'<"" _, ,_",.~__,~, .__, ~ ,__ __~."_,. 0., "'__'~ ., , Date: S /7/0;2. i. ~, , ,'-<c ""r,_~ __:-"_"_""'- - i" ~d_'h_"'I', '_0'" ". F _"i '," , "-~--- - , . GOLDBERG, KATZMAN & SHIPMAN Jefferson J. Shipman, Esquire ID. No. 51785 320 Market Street P.O. Box 1268 Harrisburg, PA 17108 Attorneys for Defendants , . , Jefferson J. Shipman, Esquire !.D. #51785 GOLDBERG, KATZMAN & SHIPMAN, P.c. 320 Market Street P.o. Box 1268 Harrisbnrg, PA 17108-1268 (717) 234-4161 Counsel for Defendants, Forrest Leek and Landstar Ranger, Inc. SUZANNE DAGGS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-5327 FORREST LEEK and LAND STAR RANGER, INC, Defendants CIVIL ACTION - LAW NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 To: Suzanne Daggs and Richard E. Freeburn, Esquire 4415 North Front Street Harrisburg, P A 1711 0 PLEASE TAKE NOTICE that Defendants intend to serve thirteen subpoenas identical to the ones that are attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned any objections to the subpoenas. If no objections are made, the subpoenas may be served. "f - ~ f:l . GOLDBERG, KATZMAN & SHIPMAN Date: 4/ ~s!Od- '""W,_l., - . Jefferson J. Shipman, Esq ire ID. No. 51785 320 Market Street P.O. Box 1268 Harrisburg, PA 17108 Attorneys for Defendants . CCtM)NWEI\LTH OF PENNSYLVANlA COUNI'Y OF C1lMBERIAND SUZMlNE DAGGS, Plainitff v. File No. 2000-5327 FORREST LEEK and LANDSTAR RANGER, INC., Defendants SUBPOENA TO PRODOCE lXXU1ENTS OR TH I NGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: HOLY SP[Rj(T HOSPITAL (N<rne of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docunents or things: any and all n\.edi;cait:tecords, correspondence, reports and dia~ostic test results pertaining to Suzanne Daggs, (DOB: 12/27/44; SS3 192-34-6932 at Goldberg, Katzman & Shipman, 320 Market Street, P.O. Box 1268, Harrisburg~ 17108 (~ddress) You may deliver or mail legible cooies of the documents or produce things requested ~y this suupoena, together with the certificate of carp liance , to the party making this request at the addr~ss listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. I f you fai 1 to produce the docunents or things required by this subpoen3. within twenty (20) days after its service, the party serving this subpoena rroy seek a court order ccrrPel1ir:g you to carply with it. THIS SUBPOENA WAS ISSUED AT THE REQJEST OF THE FOLLOI/ING PERSON: NAt-E: Jefferson J.. Shipman, Esquire ADDRESS:_!~.O. Box 1268 Harrisburg, PA WI08 TELEP~~E: 717-234-4161 SU"RE/"E <X:WT 10 # 5] 785 ATTORNEY FOR: Defendants DATE:_ ~ JX1~t ~ 4 oCOo), ~f the Court ~jl Deputy (Eff. 7/97) . . (XH1)NWEI\I;ru OF PENN$YLVl\NIA COUNI'Y OF C1JMBEID)\ND SUZANNE DAGGS, Plainitff v. File No. 2000-5327 FORREST LEEK and LANDSTAR RANGER, INC., Defendants SUBPOENA TO PR()(JtX;E DCX:XM:NTS OR TH I NGS FOR DISCOVERY PURSUANT To RULE 4009.22 TO: Internists of Central Pennsylvania (Nane of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docunents or things: any and all medicalcctecords, correspondence, reports and diagnostic test results pertaining to Suzanne Daggs, (DOB: 12/27/44; SS3 192-34-693 at Goldberg, Katzman & Shipman, 320 Market Street, P.O. Box 1268, Harrisburg, PA 17108 ( ~ddress) You may deliver or mail legible cooies of the docunents or produce things requested ~y this suupoena, together with the certificate of carpJiance, to the party making this request at the addr.e:ss listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. if you fail (20) days after a::ni:>e 11 ; r;g you to to produce the docunents or its service, the party carpIy with it. things required by this subpoen'3. within twenty servin9 this subpoena rray seek a court order THIS SUBPOENA WAS ISSUED AT "THE REOJEST OF THE FOLLa'iING PERSON; NAME: Jefferson J. Shipman, Esquire ADDRESS: _~,_O. Box 1268 Harrisburg~ PA 1'1108 TELEPHKX~E: 717-234-4161 SU'REI"E O::WT ID # 5]785 A TIORNEY FOR: Defendants OATE:_ A - c { ~f J... ~ ,)j)rJ;^ the Cou"t BY~ ~pt r Division Deputy (Eff. 7/97) <nM)NWEI\LTH OF palNSYLVANlA COUNI'Y OF aJMBERLAND SUZANNE DAGGS, Plainitff v. File No. 2000-5327 FORREST LEEK and LANDSTAR RANGER, INC., Defendants SUBPOENA TO PROQl.X;E DOCt..NENTS OR 1H I NGS FOR 0 I srovERY PURSUANT TO RULE 4009. 22 TO: Smith Radiology (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: any and all diagnostic test reports of Suza!lUe Daggs (DOB: 121~Z/4~ SS3 192-34-6932) at Goldberg, Katzman & Shipman, 320 Market Street, P.O. Box 1268, Harrisburg, PA 17108 ("'ddress) You may deliver or mail legible cooies of the documents or produce things requested by this subpoena, together with the certificate of COTPliance, to the party making this request at the addre:ss 1 isted above. You have the right to seek in advance the reasonab le cost of preparing the copies or producing the things sought. I f you fai 1 to produce the documents or things required by this subpoen3. within twenty (20) days after its service, the party serving this subpoena IT'ay seek a court order a::oi>e II ir;g you to crop 1 y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOHING PERSON: NAME: Jefferson J. Shipman, ESQnire ADDRESS:_!".O. Box 1268 Harrisburl'" PA lilI08 TELEPrKX~E: 717-234-4161 StRREl'E ccun 10 # 51785 ATTORNEY FOO: Defendants OATE:_ LLnii Jit. J..Oul ~f the COUrt Oivision Deputy (Eff. 1197) . (UoM)NWEIiliTH OF pENNSYLVANIA OJUNI'Y OF aJMBERJ)\ND SUZANNE DAGGS, Plainitff v. File No. 2000-5327 FORREST LEEK and LANDSTAR RANGER, INC., Defendants SUBPOENA TO PROD\.X;E [)(X;LM:NTS OR 11-1 I NGS FOR D I SWVERY PURSUANT TO RULE 4009.22 TO: John N. Pik:ulin, D.C. (Ncme of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docunents or things: any and all_niedica'l'crecords, correspondence, reports and dia~~tic test resnlts pertaining to Suzanne Daggs,(DOB: 12/27/441 SS3 192-34-693; at Goldberg, Katzman & Shipman, 320 Market Street, P.O. Box 1268, Harrisbnrg. PA 17108 (Address) YOIJ may deliver or mail legible cooies of the docunents or produce things requested bY this subpoena, together with the certificate of carpliance, to the party making this request at the addr-"ss listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. I f you fail (20) days after <:x:rrf>e II ing you to to produce the docunents or its service, the party carply with it. things required by this subpoena within twenty serving this subpoena IT'ay seek a court order THIS SUBPOENA WAS ISSUED AT 11-1E REQUEST OF l1iE FOLLOI/ING PERSON: NAME: Jefferson J. Shipman, ESQnire ADDRESS:_~.O. Box 1268 JIarrisburg~ PA BlO8 TELEPHKX~E: 717-234-4161 SUPREl"E <XWT ID # 5]785 ATTORNEY FOR: Defendants BY Division CXlI.A<T: DATE:. ~ An i ~~;( ()r)J ~f the Court Deputy (Eff. 7/97) . ~T!l OF PDlNSYLVANIA COUNI'Y OF aJMBERI,AND SUZANNE DAGGS, Plainitff v. File No. 2000-5327 FORREST LEEK and LANDSTAR RANGER, INC., Defendants SUBPOENA TO PR(){)UCE DCX:;U1ENTS OR TH I NGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Arlington Rehab & Sports Medicine (N1flle of Person or Ent ity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following doa.rnents or things: any and all niedi.cai::tecords, correspondence, reports and dia~ostic test resnlts pertaining to Suzanne Daggs (DOB: 12/27/44; SS3 192-34-693 at Go1dberg, Katzman & Shipman, 320 Market Street, P.O. Bo:>: 1268, Harrisburg, PA 17108 (l>,ddress) You may deliver or mail legible copies of the documents or produce things requested by this subpoena, together with the certificate of CClTPl iance , to the party making this request at the addr<,ss listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the clocunents or things required by this subpoen'3. within twenty (20) days after its service, the party serving this subpoena!!'aY seek a CDUrt order cari>ellir:g you to ccrrply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOlLOIIING PERSON: NA/'E: Jefferson J. Shipman, Esquire ADDRESS:_t,.O. Box 1268 Harrisburg~ PA BlO8 TELEPrKX4E: 717-234-4161 S\$'REl"E ~T to ~ 5178'i ATTORNEY FOR: Defendants OATE:_ ~~A aft. J /)VJ ~~the Cexrt . oivisioo Deputy (Eff. 7/97) ~Tfl Of PENNSYLVANIA COUNI'Y OF 0JMBE!1LI\ND SUZMlNE DAGGS, Plainitff v. File No. 2000-5327 FORREST LEEK and LANDSTAR RANGER, INC., Defendants SUBPOENA TO PRODU:;E D<Xll1ENTS OR TH I NGS FOR D I sroVERY PURSUANT TO RULE 4009. 22 TO: Joyner Sports Medicine Institute (Nane of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: any and all med~cai~tecords, correspondence, reports and diagn~tic test results pertaining to Suzanne Daggs,(DOB: 12/27/44; SS3 192-34-6932 at Goldberg, Katzman & Shipman, 320 Market Street, 1'.0. Box 1268. Harrisburg, PA 17108 { IIddress } You may deliver or mail legible cooies of the documents or produce things requested by this subpoena, together with the certificate of carpliance, to the party making this request at the addro?'ss listed above. You have the right to seel( ;n advance the reasonable cost of preparing the copies or producing the things sought. I f you fai 1 to produce the docunents or things required by this subpoen3. within twenty (20) days after its service, the party serving this subpoen;;. rmy seek a court order cari'>e lli r,g you to carp 1 y with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLCI'/ING PERSON: NAME: Jefferson J. Shipman, Esquire ADDRESS: P.O. Box 1268 Harrisburg, PA 1'1108 TELEPrK)!,E: 717-234-4161 SU'REJ'oE ~T ID # 517115 ATTORNEY FOR: Defendants DATE:_ A~A^rt ~4- JJ)O~ ~f the Court Deputy (Eff. 7/97) - . . , (XMof)NWEALTH OF pEllliSYLVANlA COUNI'Y OF CUMBEmAND SUZANNE DAGGS, Plainitff v. File No. 2000-5327 FORREST LEEK and LANDSTAR RANGER, INC., Defendants SUBPOENA TO PRODU:;E t:JOCU1ENTS OR 1111 NGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Heritage Diagnostic Center (Nane of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: any and all diagnostic test reports of Suzanne .Daggs (DOB: 12/27/4/n SS3 _192-34-6932) at Goldberg, Katzman & Shipman, 320 Market Street, P.O. Box 1268, Harrisburl!;~ 17108 (6,ddress) You may deliver or mail legible cDDies of the documents or produce things requested by this subpoena, together with the certificate of carpliance, to the party making this request at the addr<>ss listed above. You have the right to seek in advance the reasonab le cost of preparing the copies or producing the things sought. 1 f you fai 1 to produce the doctrnents or things required by this subpoen3. within twenty (20) days after its service, the party servin9 this subpoena rray seek a court order cart>ellir:g you to ccrrply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLCYiING PERSON: NAME: Jefferson J. Shipman, Esquire AOORESS:_!,!_O. Box 1268 Harrisburg~ PA 1~108 TELEPhKX~E: 717-234-4161 SUPREME COURT 10 # 51785 ATTORNEY FOR: Defendants OATE:_--Jpjl J. Ir J.OOl. Sea of the Cou,-t Division Deputy (Eff. 7/97) - . CCtM)NWEI\LTH OF pENNSYLVANlA COUNI'Y OF CUMBERIAND SUZANNE DAGGS, Plainitff v. rile No. 2000-5327 FORREST LEEK and LANDSTAR RANGER, INC., Defendants SUBPOENA TO PRCJDtXX DOCU1ENTS OR TH I NGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Physicians Imaging Centers (Name of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the follOWing documents or things: any and all diagnostic test reports of Suzanne Daggs (DaB: 12/27/4~ SS3 192-34-6932) at Goldberg, Katzman & Shipman, 320 Market Street, P.O. Box 1268, HarrisbuTl~~ 17108 (4ddress) You may deliver or mail legible cooies of the documents or produce things requested by this subpoena, together with the certificate of carpliance, to the party making this request at the address listed above. You have the right to seek. in advance the reasonable cost of preparing the copies or producing the things sought. 1 f you fai 1 to produce the docunents or things required by this subpoen'3. within twenty (20) days after its service, the party serving this subpoena IT'ay seek a court order carPellir;g you to carply with it. TH I S SUBPOENA WAS I SSUEO AT THE REQJEST OF THE FOLLQI/ I NG PERSON: NAME: Jefferson J. Shipman, Esquire ADDRESS:_!".O. Jlox 1268 Rarrisbnrg~ PA 1~108 TELEP~4E: 717-234-4161 SUPREME COURT 10 # ~178~ ATTORNEY FOR: Defendants OAn::_~A JjJVJ- Seal of the Court Deputy (Eff. 7/97) -- . . '. . (X)!oM)NWEI\LTH OF PENNSYLVANlA COUNl'Y OF aJMBERIAND SUZANNE DAGGS, Plainitff v. File No. 2000-5327 FORREST LEEK and LANDSTAR RANGER, INC., Defendants SUBPOENA TO PROCll.U:: [)(X;fJ1ENTS OR lli I N3S FOR D I SCX>VERY PURSUANT TO RULE 4009. 22 TO: Magnetic Imaging Center (Nane of Person or Entity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: any and all diagnostic test reports of Suzanne Daggs (DOB: 121~Z/4~ SS3 192-34-6932) at Goldberg, Katzman & Shipman, 320 Market Street, P.O. Box 1268, Harrisbnrg~ 17108 (b,ddress) You may deliver or mail legible cooies of the doct.ments or produce things requested ::'y this suupoena, together with the certificate of carpliance, to the party making this request at the addr<,:ss 1 isted above. You have the right to seel< in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the docunents or things required by this subpoen3. within twenty (20) days after its service, the party serving this subpoena rr>ay seek a court order a::rrPell ir:g you to corrply with it. llilS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLCNlING PERSON: NAME: Jefferson J. Shipman, Esquire ADDRESS:_f!_O. Box 1268 Harrisburg. PA 1~108 TELEPH(X~E: 717-234-4161 SUPREME COURT fD # 51785 ATTORNEY FOR: Defendants DATE: 1L J} I J-~ JJ;rJ) ~f the Cou,-t Division Deputy (Eff. 7/97) . , , . CCtM)NWEI\LTH OF PENNSYLVANIA COUNI'Y OF aJMI3ERl,AND SUZANNE DAGGS, Plainitff v. File No. 2000-5327 FORREST LEEK and LANDSTAR RANGER, INC., Defendants SUBPOENA TO PR()[)tX;E [)()C;l.M::NTS OR TH I NGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Pennsylvania Neurological Associates (N<rne of Person or Ent ity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following documents or things: any aud all med~cal~records, correspondence, reports and diagn~c test results pertaining to Suzanne Daggs. {DOB: 12/27/44; SS3 192-34-693" at Goldberg, Katzman & Shipman, 320 Market Street, P.O. Boz 1268, Ha=isburg~ 17108 (Address) YOI.1 rray deliver or mail legible copies of the cIocunents or produce things requested by this suupoena, together with the certificate of carpliance, to the party making this request at the addro<>.ss listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. I f you fail to produce the docunents or things required by this subpoen" within twenty (20) days after its service, the party serving this subpoena =y seek a court order cmi:>elling you to carply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOIIING PERSON: NAME: Jefferson J. Shipman, Esquire ADDRESS:_!,:.O. Box 1268 Harrisburg~ PA 1v,108 TELEPrKX,E: 717-234-4161 StPREM:: CCWT 10 # 5] 78') ATTORNEY FOR: Defendants OATE:_ L, J.1t- JJJOJ. ~f the Court Deputy (Eff. 7/97) .~ ,-~ .' +. "<!, . "" I' Jo > " ~TH OF pfllliSYl,VANlA <XlUNrY OF aJMI3E1lli\ND SUZANNE DAGGS, Plainitff v. File No. 2000-5327 FORREST LEEK and LANDSTAR RANGER, INC., Defendants SUBPOENA TO PROOtX:E OOCU'lENTS OR TH I NGS FOR DISCOVERY PURSUANT TO RULE 4009.22 TO: Malik Momin, M.D. (NIrne of Person or Ent ity) Within twenty (20) days after service of this subpoena, you are ordered by the court to produce the followinq documents or things: any and all medicai~tecords, correspondence, reports and diagnostic test resnlts pertaining to Suzanne Daggs,(DOB: 12/27/44; SS3 192-34-693: at Goldberg, Katzman & Shipman, 320 Market Street, P.O. Box 1268, Harrisbnrg~ 17108 (<\ddress) You may deliver or mail legible cooies of the ~nts or produce things requested ~y this subpoena, together with the certificate of carpliance, to the party making this request at the addr<>:ss listed above. You have the right to seell in advance the reasonable cost of preparing the copies or producing the things sought. I f you fai 1 to produce the docunents or things required by this subpoen3. within twenty (20) days after its service, the party serving this subpoena rray seek a court order <XlTi'ellir;g you to carply with it. THIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLLOIIING PERSON: NAME: Jefferson J. Shi"j)lllan, Esqnire ADDRESS:_!,-,O. Box 1268 JIarrisburg, PA B108 TELEPHKXiE: 717-234-4161 SU"REl"'E aAAlT 1D:!l 517 8 5 A TIORNEY FOR: Defendants DATE: _ ~ ^ V' L ( ~4-. c), bVJ.. ~f the Cou,-t B(!:0h1 R F ,Clrl, Division i " Deputy (Eff. 7/97) ~ _"T ~ , - . "e_ -"- ,,- --- . lio . .'. .. ./ -..>. .1 " CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing document upon all counsel of record by depositing the same in the United States Mail, certified, postage prepaid, at Harrisburg, Pennsylvania, on the d.~h day of A pi.! ,2002, addressed as follows: Richard E. Freeburn, Esquire 4415 North Front Street Harrisburg, P A 17110 GOLDBERG, KATZMAN & SHIPMAN, PC . ill FERSON lSHIPMAN, E QUIRE I.D. #51785 320 Market Street P.O. Box 1268 Harrisburg, PA 17l08-1268 (717) 234-416l Counsel for Defendants ~" HJ..~....~ II .-,- .. ........ '" .... .' " 1Io '. " CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing document upon all counsel of record by depositing the same in the United States Mail, first class, t d tH b P I th ,.,+11 dayof ///1,.,./ pos age prepai ,a arris urg, ennsy vania, on e -1. c:.L '" "'- / , 2002, addressed as follows: Richard E. Freeburn, Esquire 4415 North Front Street Harrisburg, P A l711 0 GOLDBERG, KATZMAN & SHIPMAN, PC FFERSON J. SHIPMAN, LD. #51785 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4l61 . Counsel for Defendants f" "-~~'~ "-.'"" .__"~__-"y". .,_~,.._ c_, '_"_~" _' ,_~_,__,'__ ^', Jefferson J. Shipman, Esquire I.D. #51785 GOLDBERG, KATZMAN & SHIPMAN, P.c. 320 Market Street P.O. Box 1268 Harrisbnrg, PA 17108-1268 (717) 234-4161 Counsel for Defendants, Forrest Leek and Landstar Ranger, Inc. SUZANNE DAGGS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-5327 FORREST LEEK and LANDSTARRANGER, INC, Defendants CIVIL ACTION - LAW CERTIFICATE PREREOUlSITE TO SERVICE OF A SUBPOENA PURSUANT TO RULE 4009.22 As a prerequisite to service of a subpoena for documents and things pursuant to Rule 4009.22, Defendants hereby certifY that: (1) A Notice Of Intent To Serve A Subpoena, with a copy of the subpoenas attached thereto, was mailed, via Certified Mail, or delivered to each party at least twenty days prior to the date on which the subpoenas were sought to be served; (2) A copy of the Notice OfIntent, including the proposed subpoenas, is attached to this Certificate; (3) No objection to the subpoenas has been received; and (4) The subpoenas to be served are identical to the subpoenas attached to the Notice Of Intent. ~i; 11 ii ii" ~ "~ ". - - ,-< I ~ 1- ~, ,,,"__~_. o=__~ _ "_ ,__ >-~ - . Date: q /;6 J ()? ';,'ij.." " ~. -."-,- _0' '~"'_-~,~,"_ _1'_ r "",",'_'_ 'C'_" ,,' GOLDBERG, KATZMAN & SHIPMAN By Je rson J. Shipman, Esquire ID. No. 51785 320 Market Street P.O. Box 1268 Harrisburg, PA 17108 Attorneys for Defendants ,-~ -. ~ -,' .~ -,-- ~ :,- CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing document upon all counsel of record by depositing the same in the United States Mail, first class, postage prepaid, at Harrisburg, Pellilsylvania, on the I ~+~ day of S"ente m he r , 2002, , addressed as follows: Richard E. Freeburn, Esquire 4415 North Front Street Harrisburg, P A 17110 G, KATZMAN & SHIPMAN, P.C. o By JEFFERSON lSHIPMAN, ESQUIRE I.D. #5l785 320 Market Street P.O. Box l268 Harrisburg, PA 17108-1268 (717) 234-4161 Counsel for Defendants ~ ! II II fl, , I: il I, I, !i ii II II ;, i, II " II IL . ',., ,- ~, ,~ ., , - , ,~, Jefferson J. Shipman, Esquire !.D. #51785 GOLDBERG, KATZMAN & SlDPMAN, P.C. 320 Market Street P.O. Box 1268 Harrisbnrg, PA 17108-1268 (717) 234-4161 Counsel for Defendants, Forrest Leek and Landstar Ranger, Inc. SUZANNE DAGGS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000-5327 FORREST LEEK and LANDS TAR RANGER, INC., Defendants CIVIL ACTION - LAW NOTICE OF INTENT TO SERVE SUBPOENA TO PRODUCE DOCUMENTS AND THINGS FOR DISCOVERY PURSUANT TO RULE 4009.21 To: Suzanne Daggs and Richard E. Freeburn, Esquire 4415 North Front Street Harrisburg, P A 17110 PLEASE TAKE NOTICE that Defendants intend to serve three subpoenas identical to the ones that are attached to this notice. You have twenty (20) days from the date listed below in which to file of record and serve upon the undersigned any objections to the subpoenas. If no objections are made, the subpoenas may be served. ",.p"'~, . Date: f / )-() / () ) I"'~^ By Jefferson J. Shipman, Esquire ID. No. 51785 320 Market Street P.O. Box 1268 Harrisburg, P A 17108 Attorneys for Defendants -. : CERTIFICATE OF SERVICE I HEREBY CERTIFY that I served a true and correct copy of the foregoing document upon all counsel of record by depositing the same in the United States Mail, certified, postage prepaid, at Harrisburg, Pennsylvania, on the '? d-M day of At~ cl.IS+ J ,2002, addressed as follows: Richard E. Freeburn, Esquire 4415 North Front Street Harrisburg, PA l7110 By JEFFERSON lSHlPMAN, ESQUIRE LD. #51785 320 Market Street P.O. Box 1268 Harrisburg, PA 17108-1268 (717) 234-4l61 Counsel for Defendants , ':,."""-, ~~ I! , Suzanne Daggs, Plaintiff CXMoONWElU.TH OF PlllNSYLVANIA 0JUNrY OF aJMIlERI:AND v. Forrest Leek and Landstar Ranger, Inc., Defendants File No. 2000-5327 SUBPOENA TO PR<JOlX;E DOC:lM::NTS OR TH I NGS FOR D I SO)VERY PURSUANT TO RULE 4009. 22 TO: Center for Women's Health (Nane of Person or Entity) Within twenty (20) days after s~-vice of this subpoena, you are ordered by the court to produce the follOWing docunents or things: any and all medical rffi!Qrds, reports, corresp,;,nd~n~e, l~ -t d to those oX !Jr. anne Ma.l.l~ Ma.u..u.':""""b perta1Dl..ng diagnostic test results including but not 1m1 e ------ to Suzanne Daggs SSN: 192-34-6932 DOB 12/27/44 at Goldberg, Katzman & Shipman, 320 Market Street, P.O. Box 1268, Harrisburg, PA 17108-1268 ( ^,ddress ) You may deliver or mail legible cooies of the documents or produce things requested ~y this subpoena, together with the certificate of =rpliance, to the party making this request at the addr~ss listed above. You have the right to see~ in advance the reasonable cost of preparing the copies or producing the things sought. 1 f you fai 1 to produce the docunents or things required by this subpven'il within twenty (20) days after its service, the party serving this subpoena IT'ay seek a court order carPellir;g you to carply with it. TI-lIS SUBPOENA WAS ISSUED AT THE REQUEST OF THE FOLlCWIN3 PERSON: NAME: Jefferson J.Shivman, Esquire ADDRESS: Goldberg, Katzman & Shipman, P.C. 320 naLk~L bLL~~L, P.B. BUA 12G8 RaTTi ~hnre: ....--EA...l.1lil8-] 2.68 TElEP~,E: 717-?1~-~1~1 SUPREME COURT ID #51785 ATTORNEY FOR, Defendants )ATE:_ {],. - fer ;It')o~ ~f th~ Court - Prothonotary/Cler ,Ci Division o O/).-R - P. ryO?/l-OlJ~ Deputy '----- (Eft. 7/97) ..,,-"w"" -_~ ! <XMDNWEI\LTH OF pENNSYLVANlA COUNI'Y OF aJMBERIAND Suzanne Daggs, Plaintiff v. Forrest Leek and Landstar Ranger, Inc., Defendants File No. 2000-5327 SUBPOENA TO PRODU.:;E DOClt1ENTS OR n; I NGS FOR D I S<X>VERY PURSUANT TO RUlE 4009. 22 TO: Family Physician Associates (Nane of Person or Entity) within twenty (20) days after service of this subpoena, you are ordered by the court dto . . any and allllledica1 records, reportf;i,correspon ence produce the followH1g docunents or thmgs, diagnostic test results inclnding but not limited to th~se of Dr. John Stoner pertainlng to ~Iz~nne nag~s SSN: 192-34-6932 DOB 12/27/44 320 Market Street, P.O. Box 1268, Harrisburg, PA 17108-126g- at C'..oldhPTg, Katzman & Shipman, (6.ddress) You may deliver or mail legible cooies of the docunents or produce things requested by this subpoena, together with the certificate of carpliance, to the party making this request at the addr~ss listed above. You have the right to seek in advance the reasonable cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoena within twenty (20) days after its service, the party serving this subpoena rr>ay seek a court order .carPelling you to corrply with it. 1tilS SUBPOENA WAS ISSUED AT THE REWEST OF THE FOLLCIt'/ING PERSON: NA/'E: Jefferson J. Shipman, P.C. Goldberg, Katzman il< "hipmau, P.C. ADDRESS: -3120 Market Street, ~.U.>>ox 1268 -Harri5lmrg ,-CFA--171ll11-176R TELEP~~E: 717-234-4161 SUPREl'E aJUlT ID ~ 51785 ATTORNEY Fffi: Defendants BY DATE'_ [)..- ---13 .:lty,~ ~f the 'court ----- "--- Prothonotary/Clerk, Ci . Division ~/) n P ~rj)'/uv.l ~ Deputy (Eff. 7/97) CCtM)NWEI\LTH OF PENNSYLVANlA a:xJNI'Y OF aJMBERIAND Suzanne Daggs, Plaintiff v Forrest Leek and Landstar Ranger, Inc., Defendants File No. 2000-5327 SUBPOENA TO PRClCll.O: DCX::U'1ENTS OR ill I NGS FOR 01 SCX>VERY PURSUANT TO RULE 4009. 22 TO: Harrisbnrg Hospital (Ncrne of Person or Entity) within twenty (20) days after service of this subpoena, you are ordered by the court to produce the following docunents or things: any and all medical records, reports, correspondence n;~~nQ~;~ ~PQ~~p~11~~ pp-ytainiD2 to Suzanne Daggs SSN: 192-34-6932 nOR 12/27/44 at Goldberg, Katzman & Shipman, 320 Market Street, P.O.Rm< '1268, Harrisburg, PA 17108-1268 (~ddress) You nay deliver or mail legible copies of the documents or produce things requested ~y this subpoena, together with the certificate of carpliance, to the party making this request at the addr<"ss I isted above. You have the right to seek in advance the reasonab le cost of preparing the copies or producing the things sought. If you fail to produce the documents or things required by this subpoen~ within twenty (20) days after its service, the party serving this subpoena rray seek a court order <X11i>ellir:g you to carply with it. 1]; I S SUBPOENA WAS I SSUED AT THE REQUEST OF TIlE FOLLO// I NG PERSON: NAI'E: Jefferson J. Shipman, Esquire Goldberg, Katzman & Shipman, P.C. ADDRESS:__~.M4rkLt Street, P.O.Box 1268 Harrisbur~A 17108-1268 TELEP~~E: 717-234-4161 SUPREME COURT 10 # 51785 ATTORNEY Fffi: npfend"nts BY ------- DATE: ~ tq dcY~?-- Sea I 0 the CoUrt '- <.....-. (Eff. 7/97) '" "~,-, , ." ,. t'n- ] "."~ - , "+-----J>cC.'.;C"l'V;'-- C:;J rv (J') " -0 o -" __:1 :l'::U o ~ 2jt:,_: ""---_.J_' --r ~;~ ?-~ ~':"- '~'"' ~~;~ J:-.c :2': =~ ::::2 ...lo" ~~ -< L0 -'.,) .;::- 1I!l.......!I\lQIIlIllI!1HI\II ~ _ _,," _ ~1'l'IIfi~ ,~.IV- 'q ~_~!\!lI''''I';li!~.if1''1'-<.j'MlM''',"1'~''~l\'llfh''''''\~''H'l!tw'~.;m''HFJ''''1:tM1l1\'!_Jl'''!'';\1l'~!IiIllOIlif1lllml SUZANNE DAGGS, Plaintiff v. FORREST LEEK; and LANDSTAR RANGER, INC. TO: Prothonotary IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-5327 CIVIL ACTION - LAW PRAECIPE Kindly mark the above-captioned matter settled and discontinued. By: Date: 1/27/03 ~ . y Respectfully submitted, FREEBURN & HAMILTON 1JZ,1 ~v Richard E. Free urn~squire LD. No. 30965 4415 North Front Street Harrisburg, PA 17110 (717) 671-1955 Attorney for Plaintiff